Julio Cruz v. Ashdokya, Corp., 8:24-cv-02473

Julio Cruz filed a complaint alleging violations of the Americans with Disabilities Act (ADA) and California state laws, including the Unruh Civil Rights Act, related to construction-related accessibility claims.
The complaint asserts supplemental federal jurisdiction over the state-law claims, as the ADA provides original federal jurisdiction.
California has enacted heightened requirements for Unruh Act/accessibility claims, particularly by plaintiffs considered "high-frequency litigants."
Plaintiff Cruz has filed more than ten similar actions in the past year, making him potentially a "high-frequency litigant" under California law.
The court notes that the purpose of the California statutes is to curb litigation abuse by frequent claimants, who may circumvent state requirements by filing in federal court.
The court issued an Order to Show Cause, requiring Cruz to explain why supplemental jurisdiction over the state-law claims should be retained and to provide evidence regarding his "high-frequency litigant" status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the federal court should retain supplemental jurisdiction over state law claims for accessibility violations (Unruh Act) when plaintiff is a high-frequency litigant and California law imposes additional requirements on such claims	Likely argues efficiency, fairness, and completeness support keeping all claims together in federal court	Likely contends that state law requirements and interest in regulating such claims justify declining supplemental jurisdiction	The court questions exercising jurisdiction, orders Plaintiff to show cause why it should not be declined

United Mine Workers v. Gibbs, 383 U.S. 715 (defining the discretionary nature of supplemental jurisdiction)
Nishimoto v. Federman-Bachrach & Assocs., 903 F.2d 709 (setting out factors for supplemental jurisdiction: judicial economy, convenience, fairness, and comity)